2015 Ruling 2015-0604051R3 - Internal Reorganization -- summary under Subsection 212.3(2)

In connection with a s. 55(3)(a) distribution of a Canadian subsidiary (Canco3) to a sister chain of companies held by U.S. parents, s. 212.3(2) rulings were granted based on very extensive representations about arm’s transactions not occurring as part of or before the series.